Case Law Details
Even if the amount received on behalf of other person, satisfaction note and notice u/s 158BD issued in the name of receiver of income can still be held valid
Brief Facts
1. One search and seizure operation was carried out in respect of Batra group on 17.12.1999. During the course of search, the Revenue came across certain documents which formed the basis of a Satisfaction Note recorded under Section 158BD on 30.05.2002. Soon thereafter, notice was issued on 03.06.2002 and served on the assessee .
2. The document forming basis of the Satisfaction Note was a receipt executed sometime in 1999. The receipt stated “That the total deal has been settled/fixed between me and purchaser at Rs.33,00,000/- (Rupees Thirty Three Lakhs only).
3. The searched parties, i.e. the two Batra brothers, partner of M/s Om and S. Constructions had secured the roof rights and disclosed the consideration of ₹4 lacs as to the amounts indicated in the receipt. Mr.B.L.Goel, the assessee’s father was the Power of Attorney holder of the original owner Mr. B.B. Bhagat, on the basis of a document executed in 1991
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